3-Judge bench of Apex Court held that mere pendency of civil proceeding (divorce, maintenance, dvc etc) is not a good ground and justification to not register and investigate an FIR if a criminal offence has been committed.
Citations : [2020 SCC ONLINE SC 341], [2020 (2) Crimes 261 (SC)], [2020 (5) CTC 464]
Other Sources :
https://indiankanoon.org/doc/37685877/
https://www.casemine.com/judgement/in/5e78e5bf3321bc362da2b770
https://www.indianemployees.com/judgments/details/m-subramaniam-and-another-versus-s-janaki-and-another